[DNFSB LETTERHEAD]
March
8, 2005
The
Honorable Linton Brooks
Administrator
National
Nuclear Security Administration
U.S.
Department of Energy
1000
Independence Avenue, SW
Washington,
DC 20585-0701
Dear
Ambassador Brooks:
On
November 3, 2004, the Defense Nuclear Facilities Safety Board (Board) wrote a letter to the Department of Energy
concerning the lack of adequate configuration management for vital safety
systems at Lawrence Livermore National Laboratory (LLNL). Your interim response of January 4, 2005,
acknowledged the Board’s concerns and committed to taking several actions to
expedite the implementation of an adequate configuration management program for
defense nuclear facilities at LLNL. In
your response, you noted that an assessment by the National Nuclear Security
Administration (NNSA) had identified or confirmed “serious vulnerabilities in
the configuration management program at the institutional level and in the
majority of the reviewed vital safety systems within Building 332”. The configuration management program for the
Plutonium Facility at LLNL is an
administrative control program in the Technical Safety Requirements and a specific condition for operations in
the Authorization Agreement.
A report issued on January 6, 2005, by
the Department of Energy’s Office of Independent Oversight and Performance
Assurance identified serious deficiencies in a number
of additional administrative control programs mandated by the Technical Safety
Requirements for the Plutonium Facility.
This report also identified significant deficiencies in the analyses
supporting the functionality of certain safety systems. As a result
of this assessment, LLNL declared violations of its Technical Safety
Requirements for seven administrative control programs: the Configuration Management Control Program,
the Radiation Protection Program, the Unreviewed Safety Question Program, the
Maintenance Program, the Quality Assurance Program, Occurrence Reporting, and
Procedures. Moreover, several potential
inadequacies of the documented safety analysis have been declared to address
deficiencies in supporting analyses for safety systems.
LLNL
subsequently suspended programmatic operations in the Plutonium Facility pending
the development and implementation of compensatory measures to address the identified
deficiencies in these administrative control programs. Since that time and on a case-by-case basis, however, LLNL has
undertaken, with the concurrence of NNSA’s Livermore Site Office (LSO), certain
operations considered critical but low risk.
More
recently, in a letter to LSO dated February 9, 2005,
LLNL requested approval of a set of compensatory measures to allow the
resumption of a substantial number of programmatic nuclear operations in the
Plutonium Facility. LSO has approved
these compensatory measures, subject to certain additions and clarifications,
and, according to its approval letter, intends to authorize the proposed
nuclear operations following verification of the compensatory measures.
The
result of such an action would be the resumption of programmatic operations in
the Plutonium Facility with seven inadequate safety management programs. The Board is concerned that the approach being
taken by LSO to resolve identified
deficiencies and resume nuclear operations does not adequately address the
safety issues raised by the above violations of Technical Safety Requirements
and by the identified deficiencies in safety system analysis. Therefore, pursuant to 42 U.S.C. § 2286b(d),
the Board requests a report from NNSA on the path forward
for resumption of programmatic operations in the Plutonium Facility. This report should specifically address the
following:
Should
restart of nuclear operations be
based on interim compensatory measures, the report should also address the
following:
In
addition, since nuclear safety management programs at LLNL are generally considered to be most
mature in the Plutonium Facility, the widespread declaration of violations of administrative
control programs in this facility raises questions about the condition of
similar programs at other nuclear facilities.
Therefore, the Board would also like this report to address NNSA’s
assessment of the condition of safety management programs mandated by the
Technical Safety Requirements at the other defense nuclear facilities at LLNL.
The
Board requests that NNSA provide this report prior to the resumption of programmatic operations in the
Plutonium Facility.
Sincerely,
John
T. Conway
Chairman
c: Mr. Mark B. Whitaker, Jr.